This is in follow-up to my letter of February 2, 1979, concerning your July
28, 1978 request for a permanent variance from the following sections of the
Coke Oven Emissions Standard for your Massillon Steelmaking Facility:

1910.1029(f)(2)(i)(g) - Mechanized gooseneck and standpipe
cleaners;

1910.1029(f)(4)(i) - Filtered air for operating cabs; and,

1910.1029(f)(4)(ii) - Standby pulpits - wharf.

Your application has been reevaluated and, although the rationale for the
decision as presented in Mr. Concannon's letter to you dated November 22,
1978, is certainly still valid, a determination has been made concerning
section 1910.1029(f)(2)(i)(g) which may clarify your situation concerning
standpipe cleaning. Section 1910.1029(f)(3)(i) (a)(2) requires that
standpipes be inspected prior to each charge, and cleaned to a specified
minimum diameter sufficient to effectively move the evolved gases from the
ovens to the collector mains. Although it would be your responsibility to
determine this minimum diameter based upon the configuration of your
standpipes, OSHA will generally consider that standpipes should be cleaned
when 20 percent or more of the cross-sectional area of the standpipe is
blocked. If this buildup does not occur, cleaning would not be necessary.
Finally, if cleaning is necessary, the use of air on the pusher ram with
modified air nozzles to clean standpipes has been ruled to be an acceptable
type of mechanized standpipe cleaner as long as a work practice is adopted
which requires the pusher machine operator to stop the pusher ram under the
standpipe to be cleaned and to use the air on the pusher ram to clean the
standpipe. Such a system has been developed by the National Steel
Corporation.

With regard to your request for variance from the other two sections of this
standard, although it does not meet the requirements for variance, it was
discussed with our technical staff. It is OSHA's belief that the matter of
the use of the filtered air lunchroom in lieu of a standby wharf pulpit could
be clarified based upon maintaining the present size, number of personnel,
and other pertinent factors of your facility. However, any clarification
would absolutely necessitate the use of positive-pressure, temperature
controlled filtered air for the operating cab of the larry car, as required
in Section 1910.1029(f)(4)(i).

It is OSHA's decision, however, that exemption from the remaining
requirements of Section 1910.1029(f)(4)(i) could not be permitted and that
the proposed alternative does not afford the employer protection equivalent
to that provided by the standard, as is required for a variance request. If
you desire to discuss any other approach for exemption from Section
1910.1029(f)(4)(i) based upon the closing of the Missillon Facility, please
contact Mr. Martonik.

I sincerely hope that this information will be of benefit to you and that
all parties can arrive at an amicable solution to your problem.

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